4 October 2020

SYMBIOSIS LAW SCHOOL, PUNE

SYMBIOSIS INTERNATIONAL (DEEMED) UNIVERSITY

ALTERNATIVE DISPUTE
RESOLUTION SYSTEMS
INTERNAL- I

ANALYSE & EXPLAIN THE SCOPE:

SINGAPORE MEDIATION CONVENTION

DHARMINDER SINGH KALEKA

5th Year- BA LLB (Class of 2021) | PRN: 16010125027
Contact: +91- 7299100006

SUBMITTED TO: PROF. S. KULKARNI

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Dharminder Singh Kaleka

Div- A, 5th Year, BA LLB (Hons.)
PRN- 16010125027

ANALYSE & EXPLAIN THE SCOPE: SINGAPORE MEDIATION CONVENTION

Contents:

1. Introduction: Page 3

2. Background: Page 3

3. Scope and Significance Page 4

4. Analysis of the Convention Provisions: Page 6

5. Uncertainties and Recommendations: Page 9

6. Importance for India: Page 10

7. Conclusion: Page 12

8. Bibliography: Page 13

Total Words: 4564

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INTRODUCTION

The United Nations Convention on International Settlement Agreements resulting from

Mediation popularly known as the Singapore Convention on Mediation is an international
agreement recognising and accepting mediated settlements at a global stage. This Convention has
set the stage for a global, uniform and an effective mediation framework as an agreement for
international settlements in commercial disputes. The Singapore Convention aims to harbingers a
sea of change in the stage of world trade and commercial activities by allowing parties at
loggerheads to resolve disputes and settle agreements across borders. International Trade and
businesses with the ratification of the Convention shall benefit as an additional mechanism to settle
disputes across borders has been created rather than litigation and arbitration.
The main objective of the Singapore Convention remains the enforceability of those agreements
which have been accepted by the contending parties across borders. Earlier on no assistance could
be provided to parties enforcing settlement agreements accepted via mediation.1 The only
alternative in such cases then available would have been to chose to course of litigation or
arbitration. Due to absence such a mechanism, mediation as a whole was avoided as method to
resolve disputes if the parent countries had no domestic legislation or framework for international
commercial mediations.2

BACKGROUND

The United States in the year 2014 proposed for the establishment of a global mediation
mechanism but wasn’t able to garner the required attention on the subject matter despite a lot debate
and discussion. Though, it did not had the required effect as United States had anticipated, it lead to
the United Nations Commission on International Trade’s Working Group II to further discuss the
issue in 2015. Majority of the global stakeholders accepted this move other than the European
Union as it viewed that dispute resolution should be mediated under domestic legislations.3

1 Bryan H. Hulka, Dispelling the Myths of Modern Mediation, 21 Golden Gate U. L. Rev. (1991) available at https://
www.mlaw.gov.sg/content/minlaw/en/news/press-releases/Press-Release-Singapore-Convention-on-Mediation-Opens-
for-Signature-on-7-August.html
2 S. I. Strong, Beyond International Commercial Arbitration? The Promise of International Commercial Mediation, 45
Wash. U. J. L. & Pol'y 011 (2014) available at https://openscholarship.wustl.edu/law_journal_law_policy/vol45/iss1/7
at 27.
3Timothy Schnabel, The Singapore Convention on Mediation: A Framework for the Cross-Border Recognition and
Enforcement of Mediated Settlements, 19 PEPP. DISP. RESOL. L.J. 1, 60 (2019).
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Later in the year 2018, a draft for the Convention was approved by the UNCITRAL, after three
long years of intense discussions and deliberations. It was adopted as the United Nations
Convention on International Settlement Agreements by the UN General Assembly on 18 December
2018 and opened for signatures on 7th of August next year. It was signed first by 46 member states
in August 2019 and has 53 signatories as of today. It has been ratified by six nations which include
Belarus, Ecuador, Fiji, Qatar, Saudi Arabia and Singapore. The Convention came into effect on 12th
September 2020 on completing six months after the third ratification of the Convention was done
by Qatar.

SCOPE AND SIGNIFICANCE

The Singapore Convention is a binding agreement which promotes international commercial

mediation and facilitates international trade which in term also becomes significant as it contributes
to the promotion of Sustainable Development Goal 16 which is s about "peace, justice and strong
institutions.”
Over the past few years, it has been observed that in commercial law and trade mediation has been
on a rise in sectors including rescue and insolvency, traditionally where it wasn’t applied.
Proponents of Mediation as an exercise to settle disputes often term it as a confidentiality exercise
which is cost effective as well as non-confrontational in character. The absence of cross border
enforcement at times when parties did not voluntarily abide with the terms of the settlement resulted
in a major lacuna in the enhancement of mediation. Particular instances when assets of a party were
located in foreign nations, court decrees of those local jurisdictions were required to enforce
contracts depending upon the agreed settlement.
The Singapore Convention on Mediation is applicable on cross border international commercial
disputes where “at least two parties to the settlement agreement have their places of business in
different contracting states” (Article 1.1(a)) or in which parties “have their places of business
different from either the State in which a substantial part of the obligations under the settlement
agreement is performed or the State in which the subject matter of the settlement agreement is most
closely connected” (Article 1.1(b)).4
However, the Convention does not includes a few categories of international settlements under
mediation in its scope and purview. These include settlement agreements related to party for

4United Nations Convention on International Settlement Agreements resulting from Mediation (20 December 2018),
Article 1(1).
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personal, family or household, inheritance and employment matters5 those enforceable as a

judgment or as an arbitral award (Article 1.3). Further, it expedites the process of compliance with
the settlement agreement out of the assets of the non-complying party located in another member
state.
The Singapore Convention on Mediation unlike others like the EU Mediation Directives focuses on
a direct dispensation and enforcement of the settlement in whichever country its agreed upon due to
its prior control over the member state. It means that because of the Singapore Convention, the
parties can directly reach out to the competent authorities or courts in nations where assets of non-
complying nations are present to enforce the settlement agreement. Comparable to an arbitral
award, a ‘sui generis’ status from a truly private contractual obligation is hence achieved.6
Article 4.1 of the Convention states that the party relying on the mediation agreements needs to
provide for a signed mediated settlement agreement along with required and necessary evidence to
the authorities of the State stating that it was a result of an international mediation. Further, such
authorities are bound under Article 3 of the Convention to enforce these settlements. However,
grounds to reject such a settlement by the competent authorities are also stated under Article 5 of
the Singapore Convention according to its own rules of procedure.
As several member States have different modes and mechanisms of administering and enforcing
such settlements, the Singapore Convention does not provides with a single settlement enforcement
method. The New York Convention also tried to follow a similar approach by refraining from
binding member states with a single mechanism or institution of rules and procedures to follow for
enforcing foreign awards other than in matters of documentation under Article IV and V. But still as
against the arbitration system in 1958, mediation remains still an unconventional for several
domestic legal systems. The system of alternate dispute resolution has still not be legislated and
decided on in several countries. Therefore, there are still reasonable apprehensions on the scope and
applicability of a similar policy to earlier accepted in the New York Convention and now for the
Singapore Mediation Convention.

5 Ibid, Article 1(2).

6T. Schnabel, The Singapore Convention on Mediation: A Framework for the Cross-Border Recognition and
Enforcement of Mediated Settlements, 19 Pepp. Disp. Resol. L.J. 1 (2019).
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ANALYSIS OF THE CONVENTION PROVISIONS

The United Nations Convention on International Settlement Agreements Article 1 provides

for age definition and the scope of its applicability.7 It has been accepted based to an agreement
based on mediation. It states that the agreement which is achieved by this international commercial
mediation needs to be in writing. Further exclusions under sub-sections 2 and 3 are provided for
enforceability of such settlements as those of 'personal, family, or household purposes'8 or to
'family, inheritance or employment law.’9 Those agreements which are approved by Courts as
judgments or as arbitral awards can also not also be enforced under these provisions.
It should be understood at the very behest that the Singapore Convention can only enforce
international commercial dispute settlements arising from mediation. Although, the term
‘commercial’ has not been defined under this Convention. The UNCITRAL Working Group- II
during the deliberations to draft this Convention accepted to interpret terms like ‘commercial’ in the
widest and broadest possible sense.10 They agreed to not at all include matters which concern family
and household matters under sub section 2 and 3. The reasonability behind this move was to not
include matters in scope of the Convention where parties may not have equal level playing field or
bargaining chips as in matters of inheritance or other family issues where a dominance may be built
over the other by a single party. The Working Group felt that including such matters within the
domain of the Convention will lead to hesitation amongst nations as it may interfere with the rights
of equality, dignity and due process followed by several nations in their Constitutions or other
enactments, to ratify and sign this convention in the first place.11
Further, it was also argued that as the Hague Conference on Private Law which took place since
1893 already had an established mechanism to include foreign judgments in matters which were
made exceptions to this Convention. A re-inclusion of the same would have lead to an over lap in
working and functionality between the two conventions and protocols as have been established

7 Singapore Mediation Convention, Article 1.

8 Singapore Mediation Convention, Article 1 cl. 2(a).
9 Singapore Mediation Convention, Article 1 cl. 2(b).
10 Schnabel, supra note 3, at 22.
11 Schnabel, supra note 3, at 23-24.
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under the Conference. Hence, to ensure no over-lapping between the two specific exceptions under
the sub sections were created.12
Requirements for placing trust on settlements agreements reached through mediation are covered
under Article 4 of the Convention.13 The parties in the agreement need to submit the signed
agreement to the competent authority including evidence to justify that the said settlement
agreement has been reached via mediation. This can be done by getting a signed documentation
from the mediator to the agreement or by submission of any other document that proves mediation
took place before reaching this settlement. Another method is to get ‘attestation from the institute
which has administered the mediation.’ In cases where evidence in any of these forms is not
available, the parties may submit any other proof which may be deemed fit by the competent
authorities. The second sub section of Article 4 provides with times when e-communication might
be accepted. This article mainly focuses on showing the concerned authority that mediation in the
particular case has actually taken place. This is a protection provided to the parties so that no unfair
decree gets passed and no fraud in any manner takes place while enforcement takes place.
But this provision has also led to some concerns. The signature of the mediator on the settlement
agreement is a bone of contention as several mediators in the past have shown reluctance in signing
papers as they feel the confidentiality of the mediator comes in question and shows that he or she
has played an active role in the act as party to the proceedings.14 This was taken care when the draft
was being prepared of the Convention by stating that a separate certificate may be issued as a proof
by the mediator to the competent authority.
Article 5 of the Convention15 talks about the reasons based on which an enforcement by a member
state may be refused. A non complying party may submit to the authority that while settlement was
being done they had sufficient ‘incapacity’ to mediate and hence, the settlement agreement may be
declared ‘null and void, inoperative or incapable’ of being used under the domestic jurisdiction of
which the parties are subjected to;16 or in cases where the agreement can not be understood or is
ambiguous in part or as a whole. Further, in cases where the credibility of the mediator comes into
question or the standards applicable to him results in the agreement being considered inoperative.

12 Schnabel, supra note 3, at 25. pg 25.

13 Singapore Mediation Convention, Article 4.
14 Schnabel, supra note 3, at 31.
15 Singapore Mediation Convention, Article 5.
16 Singapore Mediation Convention, Article 5 cl. 1(a)(i).
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The same is to be done when the agreement reached is against the public policy of a state or when
the mediation process as a whole is against the applicable laws of the state.
Hence, the Singapore Convention provides a plethora of safeguards so as to ensure that mediation
based mechanism and scheme is not taken lightly in matters of international commercial trade and
the authorities have the power vested in them to set aside agreements, should the need arise. The
Convention also accords enough powers to the ratifying states to set aside decisions which are
agains the basic domestic nature of laws of the respective state. The above provisions also guarantee
that enough reason and care has been taken to safeguard parties from frauds and other disputes of
criminal nature being tried in mediation via this mechanism. Although, the Convention does not
provides a free pass to the authority to reject a valid claim only if it deems fit. Reasonable care and
protection is also granted upon the party seeking enforcement of the agreement. The thought behind
such a nature of draft is to not allow Article 5 of the Convention to become a hindrance in the
process of enforcement of the dispute settlement agreement. It can only come into effect if one of
the party submits an application for the power of article 5 to be exercised in the subject matter. Had
such a wide discretion been granted to the authority, mediation as a process would have suffered
like litigation and arbitration. The grounds provided for the rejection under article five have not
been made mandatory but exhaustive.17
Futher, Article 618 provides for cases when parallel claims are moved by the parties for enforcement
under the same settlement agreement completed through mediation. At such institutions the power
has been granted to the competent authority to adjourn any decision made and an order for a
security to be furnished by the defaulting group. Article 819 provides for allowance to states to
become signatories to the Singapore Convention on Mediation with specific reservations, as all
articles might not be deemed fit by all member states.
Article 12(4)20 is also of significant nature. It provides for internal rules to be applied by regional
economic integration organisations (REIO) like the European Union. Finally, Article 13(1) permits
a state that has two or more territorial units in which different systems of law apply to declare that
the Convention is to extend to all of the territorial units or only to one or more of them.21

17 Schnabel, supra note 3, at 42.

18 Singapore Mediation Convention, Article 6.
19 Singapore Mediation Convention, Article 8.
20 Singapore Mediation Convention, Article 12(4).
21 Singapore Mediation Convention, Article 13(1).
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UNCERTAINTIES AND RECOMMENDATIONS

The unfamiliarity of numerous domestic legal systems with the concept of mediation is a
fact. Subsequently, the determination of a specific model of invocation is necessary for proper
enforcement of a mediated settlement agreement. If not for that, the lack of a model would lead to
uncertainty arising from the jurisdiction of the contracting States. Lack of a certain and clear
mechanism would lead to various practical difficulties to be faced in the enforcement of the
mediated settlement agreements. Furthermore, mediation fails to be acknowledged as an alternative
dispute settlement agreement in the domestic legal system.
One of the primary reasons behind there being room for healthy scepticism over the Singapore
Convention is the uncertainty over how the same shall be applied and operationalised. The various
facets it has shall be considered in turn. What needs to be understood is that as most arbitration
practitioners may think with a bit of gloating, the take-up rate of the Singapore Convention is still
not how it was expected to be. The very effectiveness of a treaty is based on how widely it is
adopted and accepted. This makes the Convention look like it’s still in its infancy when compared
to the New York Convention. It is to be observed that legislation which is hinged on or influenced
by the Conciliation Model Law has been adopted in only 33 States in a total of 45 jurisdictions.
However, the comparison is flawed as the Conciliation Model Law was designed to apply in cases
where parties could not agree or had not included on a set of mediation rules into their contract.
Therefore the slow progress and adoption of the Conciliation Model Law does not necessarily bode
ill for the Mediation Model Law or the Singapore Convention.
The second reason turns out to be an open question as to how Article 12(4) of the Singapore
Convention will affect its implementation in member states of regional economic integration
organisations. Article 12(4) of the Singapore Convention provides that the Singapore Convention
“shall not prevail over conflicting rules of a regional economic integration organisation” Thus, the
enforcement of the same under the Singapore Convention would be affected by any such
preconditions imposed by the regional organisations. An example of that would be obtaining the
counter party’s consent, as required under the EU Directive on Mediation, before a settlement
agreement may be relied on.
Thirdly, Article 5(1)(d) of the Convention has the ability to conveniently limit the applicability of
this Convention. This view gas been supported by the ‘travaux préparatoires’ parties would be
allowed to “contract out” of the enforcement of their settlement agreement under the Singapore
Convention by so providing in their settlement agreement. Notwithstanding , Article 5(1)(d) might

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still be limited in effect if the courts were to adopt a strict approach towards interpreting clauses
that purport to contract out of the Singapore Convention. Legally advised commercial parties,
however, are unlikely to face an issue drafting such clauses.
It goes without saying that the preferred course of action for those contracting States that do not
have a legal framework for mediation is to have proper rules and regulations adopted so as to ensure
a smooth implementation. Firstly, those States might accept the Model Law on International
Commercial Mediation and International Settlement Agreements Resulting from Mediation as the
basis for their domestic dispute settlement meditation mechanism. The Model Law has been
developed by the Working Group II (Arbitration and Conciliation/Dispute Resolution),
simultaneously with the Convention. This helps in specifying the various requirements for a
successful mediation platform. Furthermore, the Act may serve as the domestic legal platform for
the operation of mediation and enforcement of the mediated settlement agreements. This in turn
also has the capability to inspire the competent authority in the application of the aforementioned
Convention.
The second method involves the contracting states to be able to provide a clear procedure for both
recognition and enforcement. An addition would be ratification of the same . This also has the scope
to be defined in the same by-law or ratifying instrument. This method, however, leads to an
undesirable fragmentation of law where certain international settlements can be enforced .On the
other hand the nationals of the same contracting State, or the entities whose places of business are in
that State, are forced into a position of deprivation of domestic agreements of a similar kind.

IMPORTANCE FOR INDIA

The Government of India approved signing of the Singapore Convention on Mediation in

July 2019.22 The Press Release released by the Cabinet secretariat reveals that India has decided to
be a party to the convention to ‘encourage commercial arbitration in India.’ It further states that the
Government shall be setting up a new statutory body to be named as the New Delhi International
Arbitration Centre. The government release states steps are being taken to encourage dispute
settlement in India via ADR mechanisms including those of Arbitration, Conciliation and
Mediation. For the same the government has amended the Indian Commercial Courts Act of 2015
by adding a new Chapter IIIA for pre-institution mediation and settlement in certain category of

22Cabinet approves signing of the UN Convention on International Settlement Agreements resulting from mediation by
India, PIB Delhi, VRRK/PK/SH, 31 July 2019, http://pib.nic.in/PressReleaseIframePage.aspx?PRID=1580824.
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cases. Further more, the legislative process to amend the Arbitration and Conciliation Act, 1996 has
been underway. These measures are being taken so in order to make the provisions of the Singapore
Convention to be in line with the domestic laws of India and to encourage and strengthen the
Alternative Alternative Dispute Resolution Mechanisms of the country.
In India, traditionally mediation has been practise in an informal for settling disputes for far too
long. The Panchayati Raj System of village democracy present across all villages in India often
mediates between parties and settles the disputes which are of trivial nature.23 The Courts as well
under the Civil Procedure Code’s section 8924 and Order X may direct parties for mediation or
conciliation. The Hon’ble Supreme Court of India at times has sought mediation as a strategy to
settle tricky disputes of emotional and social nature.25 One of the most landmark cases in Indian
history, the Ram Janam Bhoomi and the Babri Masjid case26 whose judgment was delivered by the
apex court in the year 2019 was sent for mediation as well. This gave a strategic importance of the
growing need for mediation for dispute resolution in the Indian legal system.
Due to rising number of road accident claims in Indian courts, the Supreme Court in the year 2019
directed the government to submit a report on the feasibility of enacting a Motor Accident
Mediation Authority in every district of India for speedy and resolution of such disputes.27
The ratification of the Convention by India will further boost the development of the ADRS system
and provide necessary incentive and growth for the development of mediation as a system to settle
disputes in India. With the increasing number of foreign direct investors and major global
companies venturing into Indian markets the burden on the India judicial system is certain to
increase. Hence, establishing laws in accordance with international conventions to settle disputes
with ease is the need of the hour.
With important government plans like ‘Atamnirbhar Bharat’ and improving the quality of ‘ease of
doing business’ it is essential to settle corporate disputes via mediation and particular for
enforcements of the same when done across borders and states. In the Indian context, it can further
be deduced and concluded that investor confidence which the Government of India wishes to

23Ankur Khandelwal, 'Assessing the Scope of Mediation in India: Upholding the Principles of Justice', Asian Dispute
Review, (© Hong Kong International Arbitration Centre (HKIAC); Hong Kong International Arbitration Centre
(HKIAC) 2010, Volume 12 Issue 2) pp. 52-56.
24 Code of Civil Procedure of 1908, § 89.
25 Mridul Godha, 'A Renewed Interest In Mediation In India', Kluwer Mediation Blog, March 30 2019, available at
http://mediationblog.kluwerarbitration.com/2019/03/30/a-renewed-interest-in-mediation-in-india/.
26 M Siddiq (D) Thr Lrs vs Mahant Suresh Das & Ors (2019), Civ. App No. 10866-10867 (India).
27 M.R. Krishnamurthy v. The New India Assurance Co. (2019), Civ. App. No. 2476-2477 (India).
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increase manifold due to the adoption and ratification of the Singapore Convention by the Indian
government.

CONCLUSION

The Singapore Convention on Mediation is indeed a game changing, farsighted document

adopted by states for a better dispute resolution system for the world of international trade and
commerce. The Working Group II has drafted the Convention with utmost care and delicacy so that
all possible conflicts which could have been created due to the adoption of this document also don’t
occur. The careful mediation and consultation conducted by the Working Group II shall actually
lead to the success of this Convention in the years to come. By making several allowances and
benefits for commercial parties across the globe, the Convention provides a unique opportunity to
settle disputes in an amicable and non confrontational manner.
The Singapore Convention upon completing six months of being ratified by three states has come in
force from 12th September 2020. The need for such a global mechanism further increases manifold
due to the ongoing Covid pandemic. Further, success remains on global ratification by all state
parties.

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BIBLIOGRAPHY

Articles:

A. Ankur Khandelwal, 'Assessing the Scope of Mediation in India: Upholding the Principles of
Justice', Asian Dispute Review, (© Hong Kong International Arbitration Centre (HKIAC);
Hong Kong International Arbitration Centre (HKIAC) 2010, Volume 12 Issue 2) pp. 52-56.
B. Bryan H. Hulka, Dispelling the Myths of Modern Mediation, 21 Golden Gate U. L. Rev. (1991)
available at https://www.mlaw.gov.sg/content/minlaw/en/news/press-releases/Press-Release-
Singapore-Convention-on-Mediation-Opens-for-Signature-on-7-August.html
C. Justine Porter, ‘The Singapore Convention on Mediation: Could 2020 be the year of
ratification?’, Panningtons Manches Cooper, January 22 2020, available at https://
www.penningtonslaw.com/news-publications/latest-news/2020/the-singapore-convention-on-
mediation-could-2020-be-the-year-of-the-ratification#_ftn3.
D. Hassan Faraj Mehrabi & Hosna Sheikhattar, ‘The Singapore Mediation Convention: a
promising start, an uncertain future’, September 5 2019, https://leidenlawblog.nl/articles/the-
singapore-mediation-convention-a-promising-start-an-uncertain-future.
E. Mridul Godha, 'A Renewed Interest In Mediation In India', Kluwer Mediation Blog, March 30
2019, available at http://mediationblog.kluwerarbitration.com/2019/03/30/a-renewed-interest-
in-mediation-in-india/.
F. S. I. Strong, Beyond International Commercial Arbitration? The Promise of International
Commercial Mediation, 45 Wash. U. J. L. & Pol'y 011 (2014) available at https://
openscholarship.wustl.edu/law_journal_law_policy/vol45/iss1/7 at 27.
G. Timothy Schnabel, The Singapore Convention on Mediation: A Framework for the Cross-
Border Recognition and Enforcement of Mediated Settlements, 19 PEPP. DISP. RESOL. L.J. 1,
60 (2019).

News Articles:

H. Cabinet approves signing of the UN Convention on International Settlement Agreements

resulting from mediation by India, PIB Delhi, VRRK/PK/SH, 31 July 2019, http://pib.nic.in/
PressReleaseIframePage.aspx?PRID=1580824.
I. The Hindu Bureau, Singapore Convention on Mediation enters into force, Hindu Business Line,
12th September 2020, https://www.thehindubusinessline.com/economy/singapore-convention-
on-mediation-enters-into-force/article32586701.ece.
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Case Laws:

J. M.R. Krishnamurthy v. The New India Assurance Co. (2019), Civ. App. No. 2476-2477 (India).
K. M Siddiq (D) Thr Lrs vs Mahant Suresh Das & Ors (2019), Civ. App No. 10866-10867 (India).

International Statutes:

L. United Nations Convention on International Settlement Agreements, 2019.

Indian Statutes:

M. The Code of Civil Procedure, 1908.

Websites:

N. Singapore Convention on Mediation, https://www.singaporeconvention.org/convention/about-

convention/.
O. Kluwer Arbitration Blog, http://arbitrationblog.kluwerarbitration.com/2019/08/31/the-
singapore-mediation-convention-what-does-it-mean-for-arbitration-and-the-future-of-dispute-
resolution/.
P. Leidin Law Blog, https://leidenlawblog.nl/articles/the-singapore-mediation-convention-a-
promising-start-an-uncertain-future.

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